Bonilla v. Alameda County District Attorney's Office
- Phyllis Hamilton
- 4:24-cv-06883
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without filing fees and faced legal bars.
Steven Wayne Bonilla and the defendants in the listed cases were affected by the dismissals with prejudice. The clerk was directed to close the cases, terminate pending motions, and return later submissions without filing them.
What happened
In Bonilla v. Alameda County District Attorney’s Office, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against various federal and state judges and state courts. He challenged matters involving his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying filing fees because he had previously been barred from proceeding without fees and had not shown that he faced an immediate danger of serious physical injury when he filed. The court also stated that the lawsuits would be barred under several legal rules even if his fee-waiver applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. She also rejected the argument that her impartiality could reasonably be questioned, noting that Bonilla had named her as a defendant in three cases but made no specific allegations against her.
The detailed version
- Bonilla v. Alameda County District Attorney's Office · No. 4:24-cv-06883
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints were nearly identical. They named various federal and state judges and state courts as defendants and sought relief concerning Bonilla’s underlying conviction and the way his other cases had been handled.
The order covers the case numbers listed in the caption. The court noted that Bonilla also had a pending federal petition challenging his detention, with appointed counsel, and was represented by counsel in state court proceedings.
Filing-fee eligibility
To the extent Bonilla sought permission to proceed without prepaying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was under imminent danger of serious physical injury when he filed. The court found that the allegations did not show such danger at the time of filing. Bonilla therefore could not proceed without paying the filing fees.
Other legal bars and dismissal
The court further stated that, even if Bonilla’s applications to proceed without prepaying filing fees were granted, the lawsuits would be barred under the rules or doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately analyze the merits of the underlying claims.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Judicial-impartiality issue
The court also addressed the fact that Bonilla named Judge Hamilton as a defendant in three of the cases. Judge Hamilton concluded that her impartiality could not reasonably be questioned based on the repetitive and frivolous nature of the filings, particularly because Bonilla made no specific allegations against her. The order cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.